2013年-CEPS欧洲政策研究中心_EU_Corporate_Tax_Reform_69页_213kb

EU Corporate Tax Reform Summary

Core Content

This report, authored by the CEPS Task Force, presents an analysis of corporate tax reform in the European Union (EU). It outlines the challenges and opportunities in creating a unified corporate tax system across member states, emphasizing the need for a balanced approach between positive integration (market-shaping tax policies) and negative integration (market-creating tax policies). The report explores two key proposals for progress toward a common corporate tax base: Home State Taxation (HST) and Optional Common Base Taxation (Optional CBT).

Main Views

1. The Need for a Coherent EU Corporate Tax Policy

• A unified corporate tax system is essential for addressing the complexities of the single market.
• The current EU tax strategy is fragmented, with multiple issues (code of conduct, savings taxation, and fiscal state aid) being addressed in isolation.
• The EU must move beyond the 1997 tax package and focus on EU-wide group taxation and a common tax base as the long-term goal.

2. Two Approaches to Achieve a Common Tax Base

• Home State Taxation (HST): Companies choose a single "home state" and are taxed based on the rules of that state. Each member state shares in the profits calculated under the home state's rules.
• Optional Common Base Taxation (Optional CBT): Member states agree on a common tax base, but companies may choose to use either the common base or their domestic tax base. This allows for flexibility while promoting convergence.

3. Challenges in Achieving a Common Tax Base

• The corporate tax base is not objectively verifiable, unlike the VAT base, which is based on cash transactions.
• The subjective nature of profit measurement under accounting standards and varying national adjustments complicate the creation of a unified base.
• Member states have not yet reached consensus on defining a common corporate tax base, despite the potential benefits.

Key Information

4. Technical and Administrative Issues

• Both HST and Optional CBT require agreement on a uniform formula for apportioning profits among member states.
• The report highlights the importance of cross-border administrative cooperation and tax base harmonization.
• The single market benefits from a common tax base, as it reduces harmful tax competition and promotes fair taxation.

5. The Role of Political and Economic Instruments

• The OECD and EU are increasingly engaging with the business community, which provides a new opportunity for coordinated reform.
• The European Commission is exploring flexible instruments such as open coordination methods and enhanced cooperation.
• Enhanced cooperation may be useful in areas like tax obstacles to the single market, but not in areas like savings taxation.

6. Comparison of HST and Optional CBT

• HST allows for flexibility in choosing a home state, which may lead to convergence over time through mutual recognition.
• Optional CBT offers a common tax base but allows companies to choose between the common and domestic bases, potentially leading to continued competition.
• Both proposals are practical steps toward a common tax base, though neither is an ideal or final solution.

Policy Recommendations

• The EU should aim to balance positive and negative integration in its corporate tax policy.
• A common corporate tax base and uniform apportionment formula are essential for the long-term stability of the single market.
• The political and institutional environment must support the development of a coherent corporate tax policy.
• Member states should be encouraged to agree on a common tax base rather than replacing domestic systems, to maintain tax sovereignty and business support.

Conclusion

• The report suggests that HST and Optional CBT are viable options for moving toward a common corporate tax base.
• A common tax base is the ideal long-term solution, but the path to it must be carefully managed to avoid divergence and erosion of the tax base.
• The political climate and new policy instruments provide a window of opportunity for reform, but consensus and coordination remain critical challenges.